To meet contractual obligations, all Humana-contracted entities, including those contracted with a Humana subsidiary that support Humana plans for Medicare, Medicaid and/or Medicare-Medicaid beneficiaries, must attest to understanding and adhering to compliance program requirements outlined in the following materials:
Humana recognizes that practitioners enrolled in the Medicare program or accredited as a durable medical equipment, prosthetics, orthotics and supplies (DME POS) provider are deemed to have met the FWA training and education requirements. If an organization is deemed, its representative will have an opportunity to record how it meets the FWA training requirement and affirm its use of the CMS content for general compliance training of its employees, and, if applicable, other individuals and entities supporting the organization in meeting contractual obligations to Humana.
However, these practitioners must still complete the compliance policy, business ethics, general compliance training and (if applicable) Medicaid and SNP components of the training. More information is available in the frequently asked questions and answers document located here.
The review and confirmation of these materials helps meet practitioners’ contractual obligation to comply with state and federal law and Humana's policies and procedures. Humana requires that organizations share this information with their employees and, if applicable, other individuals and entities supporting the organization in meeting contractual obligations to Humana.
The attestation is intended to be completed at the contract level. That is, if every practitioner in an organization has a direct contract with Humana, then each practitioner must complete the required attestation. However, if a practitioner is contracted with Humana through a group contract, the practitioner will need to coordinate within the organization to have the person responsible for compliance complete the required attestation. Please note that if an organization provides multiple functions for Humana, its compliance contact may receive an additional notification from Humana; the organization is only required to complete this attestation once.
Practitioners can complete this information online via Humana's secure Compliance website, which requires Internet access. To access the website, practitioners must be registered on Humana.com/providers or Availity.com. Detailed instructions and additional information on completing these requirements, including registration, are available here. While practitioners are encouraged to complete the compliance requirements within 30 days of notification, these requirements must be completed no later than Dec. 1, 2016.
If a practitioner, or anyone contracted with or supporting the provider entity contracted with Humana, suspects or becomes aware of potential noncompliance and/or fraud, waste and abuse, he or she must report it immediately. This may be via the Ethics Help Line at 1-877-5 THE KEY (1-877-584-3539), the Ethics Help Line Web reporting site at https://www.ethicshelpline.com or a separate, preferred method of the provider entity. Any report submitted by an individual to a non-Ethics Help Line method must be forwarded by the provider entity to Humana in a timely manner.
Questions about these requirements may be directed to Humana Provider Relations at 1-800-626-2741, Monday through Friday, 8 a.m. to 5 p.m. Central time.